The U.S. Department of Energy’s (DOE) Notice of Proposed Rulemaking (NOPR) on Grid Resiliency promoted the idea of guaranteed cost-plus-profit returns to generators that store 90 days of fuel on-site (e.g. coal and nuclear plants) and operate in competitive power markets that have capacity markets.

The merits of DOE’s claims about resiliency and its proposed solutions have beenwidelycontested. However, for the sake of argument, let’s assume for a minute that on-site fuel storage is the key to a resilient power grid.

If this is indeed the case, then the Trump administration is ignoring a huge vulnerability in the system, specifically, cost-of-service regulated coal and nuclear plants.

The Trump administration has been outspoken in its support to bring back coal use and coal jobs. And, the NOPR is certainly meant to help avoid additional coal and nuclear plant retirements in the future. But, the reality is, regulated markets have retired more coal and nuclear units and capacity than competitive markets.

U.S. EIA data on power plant retirements from 2007 - the starting point of the U.S. shale gas revolution – through 2016, revealed a total of 531 coal units were retired representing 55,674 megawatts of nameplate coal capacity. And in fact, 63% of these retired coal megawatts were cost-of-service regulated, while 35% were merchant megawatts operating in competitive markets. The remainder was capacity owned by commercial and industrial entities, primarily for on-site power needs.

Using the same data source and time period (2007-2016) examined for coal, six nuclear units have retired representing 4,770 MW of nameplate capacity, with 76.4% of that capacity located in cost-of-service areas.

The graphic in the blog intro shows coal retirements (including combined heat and power) by compensation structure and balancing authority. Balancing authorities maintain the balance between power supply and demand. Regional transmission organizations and independent system operators that facilitate competitive markets also function as balancing authorities.

As you can see, the largest amount of coal capacity loss occurred through retirement of regulated units operating in MISO and PJM. PJM had the largest amount of merchant coal retirements. And indeed, DOE’s NOPR targets PJM most directly.

But, if grid resiliency is in imminent danger, why the focus just on competitive markets? And only those competitive markets that have capacity markets?

The authority DOE used in issuing its Resilience NOPR was tied to the agency’s historic relationship to the Federal Energy Regulatory Commission (FERC), the latter having jurisdiction over competitive wholesale power markets. Therefore, DOE’s concerns limited to insuring resilience in competitive markets is likely related to limits on jurisdiction.

However, this continues to beg a fundamental question. If losing “fuel-secure” capacity is such a big problem, and regulated markets have retired a greater amount of coal and nuclear plants that store fuel onsite, why isn’t the Trump administration doing more to ensure resilience in regulated markets?

In the absense of competitive wholesale markets, states have the ultimate say on resource decisions in regulated areas. So, the Trump administration doesn’t have the same tools at its disposal to direct state decisions. But, it could go to Congress for a solution, convene regulated states to explore resilience concerns, issue voluntary resiliency guidance to states, commission studies on resiliency in regulated markets, or take other actions.

The U.S. Department of Energy’s (DOE) Notice of Proposed Rulemaking (NOPR) on Grid Resiliency promoted the idea of guaranteed cost-plus-profit returns to generators that store 90 days of fuel on-site (e.g. coal and nuclear plants) and operate in competitive power markets that have capacity markets.

The merits of DOE’s claims about resiliency and its proposed solutions have beenwidelycontested. However, for the sake of argument, let’s assume for a minute that on-site fuel storage is the key to a resilient power grid.

If this is indeed the case, then the Trump administration is ignoring a huge vulnerability in the system, specifically, cost-of-service regulated coal and nuclear plants.

The Trump administration has been outspoken in its support to bring back coal use and coal jobs. And, the NOPR is certainly meant to help avoid additional coal and nuclear plant retirements in the future. But, the reality is, regulated markets have retired more coal and nuclear units and capacity than competitive markets.

U.S. EIA data on power plant retirements from 2007 - the starting point of the U.S. shale gas revolution – through 2016, revealed a total of 531 coal units were retired representing 55,674 megawatts of nameplate coal capacity. And in fact, 63% of these retired coal megawatts were cost-of-service regulated, while 35% were merchant megawatts operating in competitive markets. The remainder was capacity owned by commercial and industrial entities, primarily for on-site power needs.

Using the same data source and time period (2007-2016) examined for coal, six nuclear units have retired representing 4,770 MW of nameplate capacity, with 76.4% of that capacity located in cost-of-service areas.

The graphic in the blog intro shows coal retirements (including combined heat and power) by compensation structure and balancing authority. Balancing authorities maintain the balance between power supply and demand. Regional transmission organizations and independent system operators that facilitate competitive markets also function as balancing authorities.

As you can see, the largest amount of coal capacity loss occurred through retirement of regulated units operating in MISO and PJM. PJM had the largest amount of merchant coal retirements. And indeed, DOE’s NOPR targets PJM most directly.

But, if grid resiliency is in imminent danger, why the focus just on competitive markets? And only those competitive markets that have capacity markets?

The authority DOE used in issuing its Resilience NOPR was tied to the agency’s historic relationship to the Federal Energy Regulatory Commission (FERC), the latter having jurisdiction over competitive wholesale power markets. Therefore, DOE’s concerns limited to insuring resilience in competitive markets is likely related to limits on jurisdiction.

However, this continues to beg a fundamental question. If losing “fuel-secure” capacity is such a big problem, and regulated markets have retired a greater amount of coal and nuclear plants that store fuel onsite, why isn’t the Trump administration doing more to ensure resilience in regulated markets?

In the absense of competitive wholesale markets, states have the ultimate say on resource decisions in regulated areas. So, the Trump administration doesn’t have the same tools at its disposal to direct state decisions. But, it could go to Congress for a solution, convene regulated states to explore resilience concerns, issue voluntary resiliency guidance to states, commission studies on resiliency in regulated markets, or take other actions.

Christina Simeone is a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program. She is also the former director of policy and external affairs at the Kleinman Center for Energy Policy. While at the Kleinman Center, Christina engaged in applied research—bringing together analytics, academics, and industry insights—to further the center's mission.

Prior to joining the Kleinman Center, Simeone served as the director of the PennFuture Energy Center for Enterprise and the Environment, where she focused on energy and climate issues that impact Pennsylvania. Simeone worked on federal energy and climate legislation as policy director at the Alliance for Climate Protection in Washington, D.C., after spending several years in Harrisburg at the Pennsylvania Department of Environmental Protection (PA DEP), where she worked on climate and energy issues in the Policy Office and as special assistant to the secretary. Additionally, she has experience in private environmental consulting and in the financial management sector.

Simeone holds a master's degree in environmental studies from the University of Pennsylvania, a B.A. in economics from the University of Miami, and B.S. in music industry from Drexel University (with a concentration in opera and piano performance). She is a board member of Philadelphia's Sustainable Energy Fund, former chair of the Climate Change Advisory Committee to the PA DEP, and former co-chair to Governor Wolf's transition team for the PA DEP.

[summary] =>
[format] => full_html
[safe_value] =>

Christina Simeone is a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program. She is also the former director of policy and external affairs at the Kleinman Center for Energy Policy. While at the Kleinman Center, Christina engaged in applied research—bringing together analytics, academics, and industry insights—to further the center's mission.

Prior to joining the Kleinman Center, Simeone served as the director of the PennFuture Energy Center for Enterprise and the Environment, where she focused on energy and climate issues that impact Pennsylvania. Simeone worked on federal energy and climate legislation as policy director at the Alliance for Climate Protection in Washington, D.C., after spending several years in Harrisburg at the Pennsylvania Department of Environmental Protection (PA DEP), where she worked on climate and energy issues in the Policy Office and as special assistant to the secretary. Additionally, she has experience in private environmental consulting and in the financial management sector.

Simeone holds a master's degree in environmental studies from the University of Pennsylvania, a B.A. in economics from the University of Miami, and B.S. in music industry from Drexel University (with a concentration in opera and piano performance). She is a board member of Philadelphia's Sustainable Energy Fund, former chair of the Climate Change Advisory Committee to the PA DEP, and former co-chair to Governor Wolf's transition team for the PA DEP.

is a senior fellow at the Kleinman Center for Energy Policy and a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program.

[format] => full_html
[safe_value] =>

is a senior fellow at the Kleinman Center for Energy Policy and a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program.

Christina Simeone is a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program. She is also the former director of policy and external affairs at the Kleinman Center for Energy Policy. While at the Kleinman Center, Christina engaged in applied research—bringing together analytics, academics, and industry insights—to further the center's mission.

Prior to joining the Kleinman Center, Simeone served as the director of the PennFuture Energy Center for Enterprise and the Environment, where she focused on energy and climate issues that impact Pennsylvania. Simeone worked on federal energy and climate legislation as policy director at the Alliance for Climate Protection in Washington, D.C., after spending several years in Harrisburg at the Pennsylvania Department of Environmental Protection (PA DEP), where she worked on climate and energy issues in the Policy Office and as special assistant to the secretary. Additionally, she has experience in private environmental consulting and in the financial management sector.

Simeone holds a master's degree in environmental studies from the University of Pennsylvania, a B.A. in economics from the University of Miami, and B.S. in music industry from Drexel University (with a concentration in opera and piano performance). She is a board member of Philadelphia's Sustainable Energy Fund, former chair of the Climate Change Advisory Committee to the PA DEP, and former co-chair to Governor Wolf's transition team for the PA DEP.

[summary] =>
[format] => full_html
[safe_value] =>

Christina Simeone is a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program. She is also the former director of policy and external affairs at the Kleinman Center for Energy Policy. While at the Kleinman Center, Christina engaged in applied research—bringing together analytics, academics, and industry insights—to further the center's mission.

Prior to joining the Kleinman Center, Simeone served as the director of the PennFuture Energy Center for Enterprise and the Environment, where she focused on energy and climate issues that impact Pennsylvania. Simeone worked on federal energy and climate legislation as policy director at the Alliance for Climate Protection in Washington, D.C., after spending several years in Harrisburg at the Pennsylvania Department of Environmental Protection (PA DEP), where she worked on climate and energy issues in the Policy Office and as special assistant to the secretary. Additionally, she has experience in private environmental consulting and in the financial management sector.

Simeone holds a master's degree in environmental studies from the University of Pennsylvania, a B.A. in economics from the University of Miami, and B.S. in music industry from Drexel University (with a concentration in opera and piano performance). She is a board member of Philadelphia's Sustainable Energy Fund, former chair of the Climate Change Advisory Committee to the PA DEP, and former co-chair to Governor Wolf's transition team for the PA DEP.

is a senior fellow at the Kleinman Center for Energy Policy and a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program.

[format] => full_html
[safe_value] =>

is a senior fellow at the Kleinman Center for Energy Policy and a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program.

Christina Simeone is a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program. She is also the former director of policy and external affairs at the Kleinman Center for Energy Policy. While at the Kleinman Center, Christina engaged in applied research—bringing together analytics, academics, and industry insights—to further the center's mission.

Prior to joining the Kleinman Center, Simeone served as the director of the PennFuture Energy Center for Enterprise and the Environment, where she focused on energy and climate issues that impact Pennsylvania. Simeone worked on federal energy and climate legislation as policy director at the Alliance for Climate Protection in Washington, D.C., after spending several years in Harrisburg at the Pennsylvania Department of Environmental Protection (PA DEP), where she worked on climate and energy issues in the Policy Office and as special assistant to the secretary. Additionally, she has experience in private environmental consulting and in the financial management sector.

Simeone holds a master's degree in environmental studies from the University of Pennsylvania, a B.A. in economics from the University of Miami, and B.S. in music industry from Drexel University (with a concentration in opera and piano performance). She is a board member of Philadelphia's Sustainable Energy Fund, former chair of the Climate Change Advisory Committee to the PA DEP, and former co-chair to Governor Wolf's transition team for the PA DEP.

[summary] =>
[format] => full_html
[safe_value] =>

Christina Simeone is a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program. She is also the former director of policy and external affairs at the Kleinman Center for Energy Policy. While at the Kleinman Center, Christina engaged in applied research—bringing together analytics, academics, and industry insights—to further the center's mission.

Prior to joining the Kleinman Center, Simeone served as the director of the PennFuture Energy Center for Enterprise and the Environment, where she focused on energy and climate issues that impact Pennsylvania. Simeone worked on federal energy and climate legislation as policy director at the Alliance for Climate Protection in Washington, D.C., after spending several years in Harrisburg at the Pennsylvania Department of Environmental Protection (PA DEP), where she worked on climate and energy issues in the Policy Office and as special assistant to the secretary. Additionally, she has experience in private environmental consulting and in the financial management sector.

Simeone holds a master's degree in environmental studies from the University of Pennsylvania, a B.A. in economics from the University of Miami, and B.S. in music industry from Drexel University (with a concentration in opera and piano performance). She is a board member of Philadelphia's Sustainable Energy Fund, former chair of the Climate Change Advisory Committee to the PA DEP, and former co-chair to Governor Wolf's transition team for the PA DEP.

is a senior fellow at the Kleinman Center for Energy Policy and a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program.

[format] => full_html
[safe_value] =>

is a senior fellow at the Kleinman Center for Energy Policy and a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program.

Christina Simeone is a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program. She is also the former director of policy and external affairs at the Kleinman Center for Energy Policy. While at the Kleinman Center, Christina engaged in applied research—bringing together analytics, academics, and industry insights—to further the center's mission.

Prior to joining the Kleinman Center, Simeone served as the director of the PennFuture Energy Center for Enterprise and the Environment, where she focused on energy and climate issues that impact Pennsylvania. Simeone worked on federal energy and climate legislation as policy director at the Alliance for Climate Protection in Washington, D.C., after spending several years in Harrisburg at the Pennsylvania Department of Environmental Protection (PA DEP), where she worked on climate and energy issues in the Policy Office and as special assistant to the secretary. Additionally, she has experience in private environmental consulting and in the financial management sector.

Simeone holds a master's degree in environmental studies from the University of Pennsylvania, a B.A. in economics from the University of Miami, and B.S. in music industry from Drexel University (with a concentration in opera and piano performance). She is a board member of Philadelphia's Sustainable Energy Fund, former chair of the Climate Change Advisory Committee to the PA DEP, and former co-chair to Governor Wolf's transition team for the PA DEP.

[summary] =>
[format] => full_html
[safe_value] =>

Christina Simeone is a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program. She is also the former director of policy and external affairs at the Kleinman Center for Energy Policy. While at the Kleinman Center, Christina engaged in applied research—bringing together analytics, academics, and industry insights—to further the center's mission.

Prior to joining the Kleinman Center, Simeone served as the director of the PennFuture Energy Center for Enterprise and the Environment, where she focused on energy and climate issues that impact Pennsylvania. Simeone worked on federal energy and climate legislation as policy director at the Alliance for Climate Protection in Washington, D.C., after spending several years in Harrisburg at the Pennsylvania Department of Environmental Protection (PA DEP), where she worked on climate and energy issues in the Policy Office and as special assistant to the secretary. Additionally, she has experience in private environmental consulting and in the financial management sector.

Simeone holds a master's degree in environmental studies from the University of Pennsylvania, a B.A. in economics from the University of Miami, and B.S. in music industry from Drexel University (with a concentration in opera and piano performance). She is a board member of Philadelphia's Sustainable Energy Fund, former chair of the Climate Change Advisory Committee to the PA DEP, and former co-chair to Governor Wolf's transition team for the PA DEP.

is a senior fellow at the Kleinman Center for Energy Policy and a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program.

[format] => full_html
[safe_value] =>

is a senior fellow at the Kleinman Center for Energy Policy and a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program.

The U.S. Department of Energy’s (DOE) Notice of Proposed Rulemaking (NOPR) on Grid Resiliency promoted the idea of guaranteed cost-plus-profit returns to generators that store 90 days of fuel on-site (e.g. coal and nuclear plants) and operate in competitive power markets that have capacity markets.

The merits of DOE’s claims about resiliency and its proposed solutions have beenwidelycontested. However, for the sake of argument, let’s assume for a minute that on-site fuel storage is the key to a resilient power grid.

If this is indeed the case, then the Trump administration is ignoring a huge vulnerability in the system, specifically, cost-of-service regulated coal and nuclear plants.

The Trump administration has been outspoken in its support to bring back coal use and coal jobs. And, the NOPR is certainly meant to help avoid additional coal and nuclear plant retirements in the future. But, the reality is, regulated markets have retired more coal and nuclear units and capacity than competitive markets.

U.S. EIA data on power plant retirements from 2007 - the starting point of the U.S. shale gas revolution – through 2016, revealed a total of 531 coal units were retired representing 55,674 megawatts of nameplate coal capacity. And in fact, 63% of these retired coal megawatts were cost-of-service regulated, while 35% were merchant megawatts operating in competitive markets. The remainder was capacity owned by commercial and industrial entities, primarily for on-site power needs.

Using the same data source and time period (2007-2016) examined for coal, six nuclear units have retired representing 4,770 MW of nameplate capacity, with 76.4% of that capacity located in cost-of-service areas.

The graphic in the blog intro shows coal retirements (including combined heat and power) by compensation structure and balancing authority. Balancing authorities maintain the balance between power supply and demand. Regional transmission organizations and independent system operators that facilitate competitive markets also function as balancing authorities.

As you can see, the largest amount of coal capacity loss occurred through retirement of regulated units operating in MISO and PJM. PJM had the largest amount of merchant coal retirements. And indeed, DOE’s NOPR targets PJM most directly.

But, if grid resiliency is in imminent danger, why the focus just on competitive markets? And only those competitive markets that have capacity markets?

The authority DOE used in issuing its Resilience NOPR was tied to the agency’s historic relationship to the Federal Energy Regulatory Commission (FERC), the latter having jurisdiction over competitive wholesale power markets. Therefore, DOE’s concerns limited to insuring resilience in competitive markets is likely related to limits on jurisdiction.

However, this continues to beg a fundamental question. If losing “fuel-secure” capacity is such a big problem, and regulated markets have retired a greater amount of coal and nuclear plants that store fuel onsite, why isn’t the Trump administration doing more to ensure resilience in regulated markets?

In the absense of competitive wholesale markets, states have the ultimate say on resource decisions in regulated areas. So, the Trump administration doesn’t have the same tools at its disposal to direct state decisions. But, it could go to Congress for a solution, convene regulated states to explore resilience concerns, issue voluntary resiliency guidance to states, commission studies on resiliency in regulated markets, or take other actions.

The U.S. Department of Energy’s (DOE) Notice of Proposed Rulemaking (NOPR) on Grid Resiliency promoted the idea of guaranteed cost-plus-profit returns to generators that store 90 days of fuel on-site (e.g. coal and nuclear plants) and operate in competitive power markets that have capacity markets.

The merits of DOE’s claims about resiliency and its proposed solutions have beenwidelycontested. However, for the sake of argument, let’s assume for a minute that on-site fuel storage is the key to a resilient power grid.

If this is indeed the case, then the Trump administration is ignoring a huge vulnerability in the system, specifically, cost-of-service regulated coal and nuclear plants.

The Trump administration has been outspoken in its support to bring back coal use and coal jobs. And, the NOPR is certainly meant to help avoid additional coal and nuclear plant retirements in the future. But, the reality is, regulated markets have retired more coal and nuclear units and capacity than competitive markets.

U.S. EIA data on power plant retirements from 2007 - the starting point of the U.S. shale gas revolution – through 2016, revealed a total of 531 coal units were retired representing 55,674 megawatts of nameplate coal capacity. And in fact, 63% of these retired coal megawatts were cost-of-service regulated, while 35% were merchant megawatts operating in competitive markets. The remainder was capacity owned by commercial and industrial entities, primarily for on-site power needs.

Using the same data source and time period (2007-2016) examined for coal, six nuclear units have retired representing 4,770 MW of nameplate capacity, with 76.4% of that capacity located in cost-of-service areas.

The graphic in the blog intro shows coal retirements (including combined heat and power) by compensation structure and balancing authority. Balancing authorities maintain the balance between power supply and demand. Regional transmission organizations and independent system operators that facilitate competitive markets also function as balancing authorities.

As you can see, the largest amount of coal capacity loss occurred through retirement of regulated units operating in MISO and PJM. PJM had the largest amount of merchant coal retirements. And indeed, DOE’s NOPR targets PJM most directly.

But, if grid resiliency is in imminent danger, why the focus just on competitive markets? And only those competitive markets that have capacity markets?

The authority DOE used in issuing its Resilience NOPR was tied to the agency’s historic relationship to the Federal Energy Regulatory Commission (FERC), the latter having jurisdiction over competitive wholesale power markets. Therefore, DOE’s concerns limited to insuring resilience in competitive markets is likely related to limits on jurisdiction.

However, this continues to beg a fundamental question. If losing “fuel-secure” capacity is such a big problem, and regulated markets have retired a greater amount of coal and nuclear plants that store fuel onsite, why isn’t the Trump administration doing more to ensure resilience in regulated markets?

In the absense of competitive wholesale markets, states have the ultimate say on resource decisions in regulated areas. So, the Trump administration doesn’t have the same tools at its disposal to direct state decisions. But, it could go to Congress for a solution, convene regulated states to explore resilience concerns, issue voluntary resiliency guidance to states, commission studies on resiliency in regulated markets, or take other actions.

Christina Simeone is a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program. She is also the former director of policy and external affairs at the Kleinman Center for Energy Policy. While at the Kleinman Center, Christina engaged in applied research—bringing together analytics, academics, and industry insights—to further the center's mission.

Prior to joining the Kleinman Center, Simeone served as the director of the PennFuture Energy Center for Enterprise and the Environment, where she focused on energy and climate issues that impact Pennsylvania. Simeone worked on federal energy and climate legislation as policy director at the Alliance for Climate Protection in Washington, D.C., after spending several years in Harrisburg at the Pennsylvania Department of Environmental Protection (PA DEP), where she worked on climate and energy issues in the Policy Office and as special assistant to the secretary. Additionally, she has experience in private environmental consulting and in the financial management sector.

Simeone holds a master's degree in environmental studies from the University of Pennsylvania, a B.A. in economics from the University of Miami, and B.S. in music industry from Drexel University (with a concentration in opera and piano performance). She is a board member of Philadelphia's Sustainable Energy Fund, former chair of the Climate Change Advisory Committee to the PA DEP, and former co-chair to Governor Wolf's transition team for the PA DEP.

[summary] =>
[format] => full_html
[safe_value] =>

Christina Simeone is a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program. She is also the former director of policy and external affairs at the Kleinman Center for Energy Policy. While at the Kleinman Center, Christina engaged in applied research—bringing together analytics, academics, and industry insights—to further the center's mission.

Prior to joining the Kleinman Center, Simeone served as the director of the PennFuture Energy Center for Enterprise and the Environment, where she focused on energy and climate issues that impact Pennsylvania. Simeone worked on federal energy and climate legislation as policy director at the Alliance for Climate Protection in Washington, D.C., after spending several years in Harrisburg at the Pennsylvania Department of Environmental Protection (PA DEP), where she worked on climate and energy issues in the Policy Office and as special assistant to the secretary. Additionally, she has experience in private environmental consulting and in the financial management sector.

Simeone holds a master's degree in environmental studies from the University of Pennsylvania, a B.A. in economics from the University of Miami, and B.S. in music industry from Drexel University (with a concentration in opera and piano performance). She is a board member of Philadelphia's Sustainable Energy Fund, former chair of the Climate Change Advisory Committee to the PA DEP, and former co-chair to Governor Wolf's transition team for the PA DEP.

is a senior fellow at the Kleinman Center for Energy Policy and a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program.

[format] => full_html
[safe_value] =>

is a senior fellow at the Kleinman Center for Energy Policy and a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program.

The U.S. Department of Energy’s (DOE) Notice of Proposed Rulemaking (NOPR) on Grid Resiliency promoted the idea of guaranteed cost-plus-profit returns to generators that store 90 days of fuel on-site (e.g. coal and nuclear plants) and operate in competitive power markets that have capacity markets.

The merits of DOE’s claims about resiliency and its proposed solutions have beenwidelycontested. However, for the sake of argument, let’s assume for a minute that on-site fuel storage is the key to a resilient power grid.

If this is indeed the case, then the Trump administration is ignoring a huge vulnerability in the system, specifically, cost-of-service regulated coal and nuclear plants.

The Trump administration has been outspoken in its support to bring back coal use and coal jobs. And, the NOPR is certainly meant to help avoid additional coal and nuclear plant retirements in the future. But, the reality is, regulated markets have retired more coal and nuclear units and capacity than competitive markets.

U.S. EIA data on power plant retirements from 2007 - the starting point of the U.S. shale gas revolution – through 2016, revealed a total of 531 coal units were retired representing 55,674 megawatts of nameplate coal capacity. And in fact, 63% of these retired coal megawatts were cost-of-service regulated, while 35% were merchant megawatts operating in competitive markets. The remainder was capacity owned by commercial and industrial entities, primarily for on-site power needs.

Using the same data source and time period (2007-2016) examined for coal, six nuclear units have retired representing 4,770 MW of nameplate capacity, with 76.4% of that capacity located in cost-of-service areas.

The graphic in the blog intro shows coal retirements (including combined heat and power) by compensation structure and balancing authority. Balancing authorities maintain the balance between power supply and demand. Regional transmission organizations and independent system operators that facilitate competitive markets also function as balancing authorities.

As you can see, the largest amount of coal capacity loss occurred through retirement of regulated units operating in MISO and PJM. PJM had the largest amount of merchant coal retirements. And indeed, DOE’s NOPR targets PJM most directly.

But, if grid resiliency is in imminent danger, why the focus just on competitive markets? And only those competitive markets that have capacity markets?

The authority DOE used in issuing its Resilience NOPR was tied to the agency’s historic relationship to the Federal Energy Regulatory Commission (FERC), the latter having jurisdiction over competitive wholesale power markets. Therefore, DOE’s concerns limited to insuring resilience in competitive markets is likely related to limits on jurisdiction.

However, this continues to beg a fundamental question. If losing “fuel-secure” capacity is such a big problem, and regulated markets have retired a greater amount of coal and nuclear plants that store fuel onsite, why isn’t the Trump administration doing more to ensure resilience in regulated markets?

In the absense of competitive wholesale markets, states have the ultimate say on resource decisions in regulated areas. So, the Trump administration doesn’t have the same tools at its disposal to direct state decisions. But, it could go to Congress for a solution, convene regulated states to explore resilience concerns, issue voluntary resiliency guidance to states, commission studies on resiliency in regulated markets, or take other actions.

The U.S. Department of Energy’s (DOE) Notice of Proposed Rulemaking (NOPR) on Grid Resiliency promoted the idea of guaranteed cost-plus-profit returns to generators that store 90 days of fuel on-site (e.g. coal and nuclear plants) and operate in competitive power markets that have capacity markets.

The merits of DOE’s claims about resiliency and its proposed solutions have beenwidelycontested. However, for the sake of argument, let’s assume for a minute that on-site fuel storage is the key to a resilient power grid.

If this is indeed the case, then the Trump administration is ignoring a huge vulnerability in the system, specifically, cost-of-service regulated coal and nuclear plants.

The Trump administration has been outspoken in its support to bring back coal use and coal jobs. And, the NOPR is certainly meant to help avoid additional coal and nuclear plant retirements in the future. But, the reality is, regulated markets have retired more coal and nuclear units and capacity than competitive markets.

U.S. EIA data on power plant retirements from 2007 - the starting point of the U.S. shale gas revolution – through 2016, revealed a total of 531 coal units were retired representing 55,674 megawatts of nameplate coal capacity. And in fact, 63% of these retired coal megawatts were cost-of-service regulated, while 35% were merchant megawatts operating in competitive markets. The remainder was capacity owned by commercial and industrial entities, primarily for on-site power needs.

Using the same data source and time period (2007-2016) examined for coal, six nuclear units have retired representing 4,770 MW of nameplate capacity, with 76.4% of that capacity located in cost-of-service areas.

The graphic in the blog intro shows coal retirements (including combined heat and power) by compensation structure and balancing authority. Balancing authorities maintain the balance between power supply and demand. Regional transmission organizations and independent system operators that facilitate competitive markets also function as balancing authorities.

As you can see, the largest amount of coal capacity loss occurred through retirement of regulated units operating in MISO and PJM. PJM had the largest amount of merchant coal retirements. And indeed, DOE’s NOPR targets PJM most directly.

But, if grid resiliency is in imminent danger, why the focus just on competitive markets? And only those competitive markets that have capacity markets?

The authority DOE used in issuing its Resilience NOPR was tied to the agency’s historic relationship to the Federal Energy Regulatory Commission (FERC), the latter having jurisdiction over competitive wholesale power markets. Therefore, DOE’s concerns limited to insuring resilience in competitive markets is likely related to limits on jurisdiction.

However, this continues to beg a fundamental question. If losing “fuel-secure” capacity is such a big problem, and regulated markets have retired a greater amount of coal and nuclear plants that store fuel onsite, why isn’t the Trump administration doing more to ensure resilience in regulated markets?

In the absense of competitive wholesale markets, states have the ultimate say on resource decisions in regulated areas. So, the Trump administration doesn’t have the same tools at its disposal to direct state decisions. But, it could go to Congress for a solution, convene regulated states to explore resilience concerns, issue voluntary resiliency guidance to states, commission studies on resiliency in regulated markets, or take other actions.

Christina Simeone is a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program. She is also the former director of policy and external affairs at the Kleinman Center for Energy Policy. While at the Kleinman Center, Christina engaged in applied research—bringing together analytics, academics, and industry insights—to further the center's mission.

Prior to joining the Kleinman Center, Simeone served as the director of the PennFuture Energy Center for Enterprise and the Environment, where she focused on energy and climate issues that impact Pennsylvania. Simeone worked on federal energy and climate legislation as policy director at the Alliance for Climate Protection in Washington, D.C., after spending several years in Harrisburg at the Pennsylvania Department of Environmental Protection (PA DEP), where she worked on climate and energy issues in the Policy Office and as special assistant to the secretary. Additionally, she has experience in private environmental consulting and in the financial management sector.

Simeone holds a master's degree in environmental studies from the University of Pennsylvania, a B.A. in economics from the University of Miami, and B.S. in music industry from Drexel University (with a concentration in opera and piano performance). She is a board member of Philadelphia's Sustainable Energy Fund, former chair of the Climate Change Advisory Committee to the PA DEP, and former co-chair to Governor Wolf's transition team for the PA DEP.

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Christina Simeone is a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program. She is also the former director of policy and external affairs at the Kleinman Center for Energy Policy. While at the Kleinman Center, Christina engaged in applied research—bringing together analytics, academics, and industry insights—to further the center's mission.

Prior to joining the Kleinman Center, Simeone served as the director of the PennFuture Energy Center for Enterprise and the Environment, where she focused on energy and climate issues that impact Pennsylvania. Simeone worked on federal energy and climate legislation as policy director at the Alliance for Climate Protection in Washington, D.C., after spending several years in Harrisburg at the Pennsylvania Department of Environmental Protection (PA DEP), where she worked on climate and energy issues in the Policy Office and as special assistant to the secretary. Additionally, she has experience in private environmental consulting and in the financial management sector.

Simeone holds a master's degree in environmental studies from the University of Pennsylvania, a B.A. in economics from the University of Miami, and B.S. in music industry from Drexel University (with a concentration in opera and piano performance). She is a board member of Philadelphia's Sustainable Energy Fund, former chair of the Climate Change Advisory Committee to the PA DEP, and former co-chair to Governor Wolf's transition team for the PA DEP.

is a senior fellow at the Kleinman Center for Energy Policy and a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program.

[format] => full_html
[safe_value] =>

is a senior fellow at the Kleinman Center for Energy Policy and a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program.

The U.S. Department of Energy’s (DOE) Notice of Proposed Rulemaking (NOPR) on Grid Resiliency promoted the idea of guaranteed cost-plus-profit returns to generators that store 90 days of fuel on-site (e.g. coal and nuclear plants) and operate in competitive power markets that have capacity markets.

The merits of DOE’s claims about resiliency and its proposed solutions have beenwidelycontested. However, for the sake of argument, let’s assume for a minute that on-site fuel storage is the key to a resilient power grid.

If this is indeed the case, then the Trump administration is ignoring a huge vulnerability in the system, specifically, cost-of-service regulated coal and nuclear plants.

The Trump administration has been outspoken in its support to bring back coal use and coal jobs. And, the NOPR is certainly meant to help avoid additional coal and nuclear plant retirements in the future. But, the reality is, regulated markets have retired more coal and nuclear units and capacity than competitive markets.

U.S. EIA data on power plant retirements from 2007 - the starting point of the U.S. shale gas revolution – through 2016, revealed a total of 531 coal units were retired representing 55,674 megawatts of nameplate coal capacity. And in fact, 63% of these retired coal megawatts were cost-of-service regulated, while 35% were merchant megawatts operating in competitive markets. The remainder was capacity owned by commercial and industrial entities, primarily for on-site power needs.

Using the same data source and time period (2007-2016) examined for coal, six nuclear units have retired representing 4,770 MW of nameplate capacity, with 76.4% of that capacity located in cost-of-service areas.

The graphic in the blog intro shows coal retirements (including combined heat and power) by compensation structure and balancing authority. Balancing authorities maintain the balance between power supply and demand. Regional transmission organizations and independent system operators that facilitate competitive markets also function as balancing authorities.

As you can see, the largest amount of coal capacity loss occurred through retirement of regulated units operating in MISO and PJM. PJM had the largest amount of merchant coal retirements. And indeed, DOE’s NOPR targets PJM most directly.

But, if grid resiliency is in imminent danger, why the focus just on competitive markets? And only those competitive markets that have capacity markets?

The authority DOE used in issuing its Resilience NOPR was tied to the agency’s historic relationship to the Federal Energy Regulatory Commission (FERC), the latter having jurisdiction over competitive wholesale power markets. Therefore, DOE’s concerns limited to insuring resilience in competitive markets is likely related to limits on jurisdiction.

However, this continues to beg a fundamental question. If losing “fuel-secure” capacity is such a big problem, and regulated markets have retired a greater amount of coal and nuclear plants that store fuel onsite, why isn’t the Trump administration doing more to ensure resilience in regulated markets?

In the absense of competitive wholesale markets, states have the ultimate say on resource decisions in regulated areas. So, the Trump administration doesn’t have the same tools at its disposal to direct state decisions. But, it could go to Congress for a solution, convene regulated states to explore resilience concerns, issue voluntary resiliency guidance to states, commission studies on resiliency in regulated markets, or take other actions.

The U.S. Department of Energy’s (DOE) Notice of Proposed Rulemaking (NOPR) on Grid Resiliency promoted the idea of guaranteed cost-plus-profit returns to generators that store 90 days of fuel on-site (e.g. coal and nuclear plants) and operate in competitive power markets that have capacity markets.

The merits of DOE’s claims about resiliency and its proposed solutions have beenwidelycontested. However, for the sake of argument, let’s assume for a minute that on-site fuel storage is the key to a resilient power grid.

If this is indeed the case, then the Trump administration is ignoring a huge vulnerability in the system, specifically, cost-of-service regulated coal and nuclear plants.

The Trump administration has been outspoken in its support to bring back coal use and coal jobs. And, the NOPR is certainly meant to help avoid additional coal and nuclear plant retirements in the future. But, the reality is, regulated markets have retired more coal and nuclear units and capacity than competitive markets.

U.S. EIA data on power plant retirements from 2007 - the starting point of the U.S. shale gas revolution – through 2016, revealed a total of 531 coal units were retired representing 55,674 megawatts of nameplate coal capacity. And in fact, 63% of these retired coal megawatts were cost-of-service regulated, while 35% were merchant megawatts operating in competitive markets. The remainder was capacity owned by commercial and industrial entities, primarily for on-site power needs.

Using the same data source and time period (2007-2016) examined for coal, six nuclear units have retired representing 4,770 MW of nameplate capacity, with 76.4% of that capacity located in cost-of-service areas.

The graphic in the blog intro shows coal retirements (including combined heat and power) by compensation structure and balancing authority. Balancing authorities maintain the balance between power supply and demand. Regional transmission organizations and independent system operators that facilitate competitive markets also function as balancing authorities.

As you can see, the largest amount of coal capacity loss occurred through retirement of regulated units operating in MISO and PJM. PJM had the largest amount of merchant coal retirements. And indeed, DOE’s NOPR targets PJM most directly.

But, if grid resiliency is in imminent danger, why the focus just on competitive markets? And only those competitive markets that have capacity markets?

The authority DOE used in issuing its Resilience NOPR was tied to the agency’s historic relationship to the Federal Energy Regulatory Commission (FERC), the latter having jurisdiction over competitive wholesale power markets. Therefore, DOE’s concerns limited to insuring resilience in competitive markets is likely related to limits on jurisdiction.

However, this continues to beg a fundamental question. If losing “fuel-secure” capacity is such a big problem, and regulated markets have retired a greater amount of coal and nuclear plants that store fuel onsite, why isn’t the Trump administration doing more to ensure resilience in regulated markets?

In the absense of competitive wholesale markets, states have the ultimate say on resource decisions in regulated areas. So, the Trump administration doesn’t have the same tools at its disposal to direct state decisions. But, it could go to Congress for a solution, convene regulated states to explore resilience concerns, issue voluntary resiliency guidance to states, commission studies on resiliency in regulated markets, or take other actions.

Christina Simeone is a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program. She is also the former director of policy and external affairs at the Kleinman Center for Energy Policy. While at the Kleinman Center, Christina engaged in applied research—bringing together analytics, academics, and industry insights—to further the center's mission.

Prior to joining the Kleinman Center, Simeone served as the director of the PennFuture Energy Center for Enterprise and the Environment, where she focused on energy and climate issues that impact Pennsylvania. Simeone worked on federal energy and climate legislation as policy director at the Alliance for Climate Protection in Washington, D.C., after spending several years in Harrisburg at the Pennsylvania Department of Environmental Protection (PA DEP), where she worked on climate and energy issues in the Policy Office and as special assistant to the secretary. Additionally, she has experience in private environmental consulting and in the financial management sector.

Simeone holds a master's degree in environmental studies from the University of Pennsylvania, a B.A. in economics from the University of Miami, and B.S. in music industry from Drexel University (with a concentration in opera and piano performance). She is a board member of Philadelphia's Sustainable Energy Fund, former chair of the Climate Change Advisory Committee to the PA DEP, and former co-chair to Governor Wolf's transition team for the PA DEP.

[summary] =>
[format] => full_html
[safe_value] =>

Christina Simeone is a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program. She is also the former director of policy and external affairs at the Kleinman Center for Energy Policy. While at the Kleinman Center, Christina engaged in applied research—bringing together analytics, academics, and industry insights—to further the center's mission.

Prior to joining the Kleinman Center, Simeone served as the director of the PennFuture Energy Center for Enterprise and the Environment, where she focused on energy and climate issues that impact Pennsylvania. Simeone worked on federal energy and climate legislation as policy director at the Alliance for Climate Protection in Washington, D.C., after spending several years in Harrisburg at the Pennsylvania Department of Environmental Protection (PA DEP), where she worked on climate and energy issues in the Policy Office and as special assistant to the secretary. Additionally, she has experience in private environmental consulting and in the financial management sector.

Simeone holds a master's degree in environmental studies from the University of Pennsylvania, a B.A. in economics from the University of Miami, and B.S. in music industry from Drexel University (with a concentration in opera and piano performance). She is a board member of Philadelphia's Sustainable Energy Fund, former chair of the Climate Change Advisory Committee to the PA DEP, and former co-chair to Governor Wolf's transition team for the PA DEP.

is a senior fellow at the Kleinman Center for Energy Policy and a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program.

[format] => full_html
[safe_value] =>

is a senior fellow at the Kleinman Center for Energy Policy and a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program.

The U.S. Department of Energy’s (DOE) Notice of Proposed Rulemaking (NOPR) on Grid Resiliency promoted the idea of guaranteed cost-plus-profit returns to generators that store 90 days of fuel on-site (e.g. coal and nuclear plants) and operate in competitive power markets that have capacity markets.

The merits of DOE’s claims about resiliency and its proposed solutions have beenwidelycontested. However, for the sake of argument, let’s assume for a minute that on-site fuel storage is the key to a resilient power grid.

If this is indeed the case, then the Trump administration is ignoring a huge vulnerability in the system, specifically, cost-of-service regulated coal and nuclear plants.

The Trump administration has been outspoken in its support to bring back coal use and coal jobs. And, the NOPR is certainly meant to help avoid additional coal and nuclear plant retirements in the future. But, the reality is, regulated markets have retired more coal and nuclear units and capacity than competitive markets.

U.S. EIA data on power plant retirements from 2007 - the starting point of the U.S. shale gas revolution – through 2016, revealed a total of 531 coal units were retired representing 55,674 megawatts of nameplate coal capacity. And in fact, 63% of these retired coal megawatts were cost-of-service regulated, while 35% were merchant megawatts operating in competitive markets. The remainder was capacity owned by commercial and industrial entities, primarily for on-site power needs.

Using the same data source and time period (2007-2016) examined for coal, six nuclear units have retired representing 4,770 MW of nameplate capacity, with 76.4% of that capacity located in cost-of-service areas.

The graphic in the blog intro shows coal retirements (including combined heat and power) by compensation structure and balancing authority. Balancing authorities maintain the balance between power supply and demand. Regional transmission organizations and independent system operators that facilitate competitive markets also function as balancing authorities.

As you can see, the largest amount of coal capacity loss occurred through retirement of regulated units operating in MISO and PJM. PJM had the largest amount of merchant coal retirements. And indeed, DOE’s NOPR targets PJM most directly.

But, if grid resiliency is in imminent danger, why the focus just on competitive markets? And only those competitive markets that have capacity markets?

The authority DOE used in issuing its Resilience NOPR was tied to the agency’s historic relationship to the Federal Energy Regulatory Commission (FERC), the latter having jurisdiction over competitive wholesale power markets. Therefore, DOE’s concerns limited to insuring resilience in competitive markets is likely related to limits on jurisdiction.

However, this continues to beg a fundamental question. If losing “fuel-secure” capacity is such a big problem, and regulated markets have retired a greater amount of coal and nuclear plants that store fuel onsite, why isn’t the Trump administration doing more to ensure resilience in regulated markets?

In the absense of competitive wholesale markets, states have the ultimate say on resource decisions in regulated areas. So, the Trump administration doesn’t have the same tools at its disposal to direct state decisions. But, it could go to Congress for a solution, convene regulated states to explore resilience concerns, issue voluntary resiliency guidance to states, commission studies on resiliency in regulated markets, or take other actions.

The U.S. Department of Energy’s (DOE) Notice of Proposed Rulemaking (NOPR) on Grid Resiliency promoted the idea of guaranteed cost-plus-profit returns to generators that store 90 days of fuel on-site (e.g. coal and nuclear plants) and operate in competitive power markets that have capacity markets.

The merits of DOE’s claims about resiliency and its proposed solutions have beenwidelycontested. However, for the sake of argument, let’s assume for a minute that on-site fuel storage is the key to a resilient power grid.

If this is indeed the case, then the Trump administration is ignoring a huge vulnerability in the system, specifically, cost-of-service regulated coal and nuclear plants.

The Trump administration has been outspoken in its support to bring back coal use and coal jobs. And, the NOPR is certainly meant to help avoid additional coal and nuclear plant retirements in the future. But, the reality is, regulated markets have retired more coal and nuclear units and capacity than competitive markets.

U.S. EIA data on power plant retirements from 2007 - the starting point of the U.S. shale gas revolution – through 2016, revealed a total of 531 coal units were retired representing 55,674 megawatts of nameplate coal capacity. And in fact, 63% of these retired coal megawatts were cost-of-service regulated, while 35% were merchant megawatts operating in competitive markets. The remainder was capacity owned by commercial and industrial entities, primarily for on-site power needs.

Using the same data source and time period (2007-2016) examined for coal, six nuclear units have retired representing 4,770 MW of nameplate capacity, with 76.4% of that capacity located in cost-of-service areas.

The graphic in the blog intro shows coal retirements (including combined heat and power) by compensation structure and balancing authority. Balancing authorities maintain the balance between power supply and demand. Regional transmission organizations and independent system operators that facilitate competitive markets also function as balancing authorities.

As you can see, the largest amount of coal capacity loss occurred through retirement of regulated units operating in MISO and PJM. PJM had the largest amount of merchant coal retirements. And indeed, DOE’s NOPR targets PJM most directly.

But, if grid resiliency is in imminent danger, why the focus just on competitive markets? And only those competitive markets that have capacity markets?

The authority DOE used in issuing its Resilience NOPR was tied to the agency’s historic relationship to the Federal Energy Regulatory Commission (FERC), the latter having jurisdiction over competitive wholesale power markets. Therefore, DOE’s concerns limited to insuring resilience in competitive markets is likely related to limits on jurisdiction.

However, this continues to beg a fundamental question. If losing “fuel-secure” capacity is such a big problem, and regulated markets have retired a greater amount of coal and nuclear plants that store fuel onsite, why isn’t the Trump administration doing more to ensure resilience in regulated markets?

In the absense of competitive wholesale markets, states have the ultimate say on resource decisions in regulated areas. So, the Trump administration doesn’t have the same tools at its disposal to direct state decisions. But, it could go to Congress for a solution, convene regulated states to explore resilience concerns, issue voluntary resiliency guidance to states, commission studies on resiliency in regulated markets, or take other actions.

The U.S. Department of Energy’s (DOE) Notice of Proposed Rulemaking (NOPR) on Grid Resiliency promoted the idea of guaranteed cost-plus-profit returns to generators that store 90 days of fuel on-site (e.g. coal and nuclear plants) and operate in competitive power markets that have capacity markets.

The merits of DOE’s claims about resiliency and its proposed solutions have beenwidelycontested. However, for the sake of argument, let’s assume for a minute that on-site fuel storage is the key to a resilient power grid.

If this is indeed the case, then the Trump administration is ignoring a huge vulnerability in the system, specifically, cost-of-service regulated coal and nuclear plants.

The Trump administration has been outspoken in its support to bring back coal use and coal jobs. And, the NOPR is certainly meant to help avoid additional coal and nuclear plant retirements in the future. But, the reality is, regulated markets have retired more coal and nuclear units and capacity than competitive markets.

U.S. EIA data on power plant retirements from 2007 - the starting point of the U.S. shale gas revolution – through 2016, revealed a total of 531 coal units were retired representing 55,674 megawatts of nameplate coal capacity. And in fact, 63% of these retired coal megawatts were cost-of-service regulated, while 35% were merchant megawatts operating in competitive markets. The remainder was capacity owned by commercial and industrial entities, primarily for on-site power needs.

Using the same data source and time period (2007-2016) examined for coal, six nuclear units have retired representing 4,770 MW of nameplate capacity, with 76.4% of that capacity located in cost-of-service areas.

The graphic in the blog intro shows coal retirements (including combined heat and power) by compensation structure and balancing authority. Balancing authorities maintain the balance between power supply and demand. Regional transmission organizations and independent system operators that facilitate competitive markets also function as balancing authorities.

As you can see, the largest amount of coal capacity loss occurred through retirement of regulated units operating in MISO and PJM. PJM had the largest amount of merchant coal retirements. And indeed, DOE’s NOPR targets PJM most directly.

But, if grid resiliency is in imminent danger, why the focus just on competitive markets? And only those competitive markets that have capacity markets?

The authority DOE used in issuing its Resilience NOPR was tied to the agency’s historic relationship to the Federal Energy Regulatory Commission (FERC), the latter having jurisdiction over competitive wholesale power markets. Therefore, DOE’s concerns limited to insuring resilience in competitive markets is likely related to limits on jurisdiction.

However, this continues to beg a fundamental question. If losing “fuel-secure” capacity is such a big problem, and regulated markets have retired a greater amount of coal and nuclear plants that store fuel onsite, why isn’t the Trump administration doing more to ensure resilience in regulated markets?

In the absense of competitive wholesale markets, states have the ultimate say on resource decisions in regulated areas. So, the Trump administration doesn’t have the same tools at its disposal to direct state decisions. But, it could go to Congress for a solution, convene regulated states to explore resilience concerns, issue voluntary resiliency guidance to states, commission studies on resiliency in regulated markets, or take other actions.

The U.S. Department of Energy’s (DOE) Notice of Proposed Rulemaking (NOPR) on Grid Resiliency promoted the idea of guaranteed cost-plus-profit returns to generators that store 90 days of fuel on-site (e.g. coal and nuclear plants) and operate in competitive power markets that have capacity markets.

The merits of DOE’s claims about resiliency and its proposed solutions have beenwidelycontested. However, for the sake of argument, let’s assume for a minute that on-site fuel storage is the key to a resilient power grid.

If this is indeed the case, then the Trump administration is ignoring a huge vulnerability in the system, specifically, cost-of-service regulated coal and nuclear plants.

The Trump administration has been outspoken in its support to bring back coal use and coal jobs. And, the NOPR is certainly meant to help avoid additional coal and nuclear plant retirements in the future. But, the reality is, regulated markets have retired more coal and nuclear units and capacity than competitive markets.

U.S. EIA data on power plant retirements from 2007 - the starting point of the U.S. shale gas revolution – through 2016, revealed a total of 531 coal units were retired representing 55,674 megawatts of nameplate coal capacity. And in fact, 63% of these retired coal megawatts were cost-of-service regulated, while 35% were merchant megawatts operating in competitive markets. The remainder was capacity owned by commercial and industrial entities, primarily for on-site power needs.

Using the same data source and time period (2007-2016) examined for coal, six nuclear units have retired representing 4,770 MW of nameplate capacity, with 76.4% of that capacity located in cost-of-service areas.

The graphic in the blog intro shows coal retirements (including combined heat and power) by compensation structure and balancing authority. Balancing authorities maintain the balance between power supply and demand. Regional transmission organizations and independent system operators that facilitate competitive markets also function as balancing authorities.

As you can see, the largest amount of coal capacity loss occurred through retirement of regulated units operating in MISO and PJM. PJM had the largest amount of merchant coal retirements. And indeed, DOE’s NOPR targets PJM most directly.

But, if grid resiliency is in imminent danger, why the focus just on competitive markets? And only those competitive markets that have capacity markets?

The authority DOE used in issuing its Resilience NOPR was tied to the agency’s historic relationship to the Federal Energy Regulatory Commission (FERC), the latter having jurisdiction over competitive wholesale power markets. Therefore, DOE’s concerns limited to insuring resilience in competitive markets is likely related to limits on jurisdiction.

However, this continues to beg a fundamental question. If losing “fuel-secure” capacity is such a big problem, and regulated markets have retired a greater amount of coal and nuclear plants that store fuel onsite, why isn’t the Trump administration doing more to ensure resilience in regulated markets?

In the absense of competitive wholesale markets, states have the ultimate say on resource decisions in regulated areas. So, the Trump administration doesn’t have the same tools at its disposal to direct state decisions. But, it could go to Congress for a solution, convene regulated states to explore resilience concerns, issue voluntary resiliency guidance to states, commission studies on resiliency in regulated markets, or take other actions.

Christina Simeone is a senior fellow at the Kleinman Center for Energy Policy and a doctoral student in advanced energy systems at the Colorado School of Mines and the National Renewable Energy Laboratory, a joint program.

Our blog highlights the research, opinions, and insights of individual authors. It does not represent the voice of the Kleinman Center.